Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

The Eighth Circuit reversed the district court's order certifying a class under Federal Rules of Civil Procedure 23(b)(2) and (b)(3), holding that the district court abused is discretion in finding that plaintiffs met the cohesiveness, and predominance and superiority requirements. In this case, plaintiff and other current and former employees of Union Pacific moved to certify a class action for a claim under the Americans with Disabilities Act (ADA). The district court granted a hybrid class defined to include all employees who have been or will be subject to a fitness-for-duty evaluation because of a reportable health event from September 18, 2014 until the end of the case.The court held that the individualized inquiries in this case cannot be addressed in a manner consistent with Rule 23; determining whether the policy is job related and consistent with business necessity requires answering many individual questions; both the text of the ADA and the record evidence demonstrate that the district court would be required to consider the unique circumstances of each position in question to determine whether the policy is unlawfully discriminatory; and thus these individualized questions defeated both predominance and cohesiveness. View "Harris v. Union Pacific Railroad Co." on Justia Law

Plaintiffs filed a putative class action against former trustees of the Lifetouch Plan, the Board, and Lifetouch, alleging claims under the Employee Retirement Income Security Act (ERISA). The Eighth Circuit affirmed the district court's dismissal of the amended complaint for failure to state a claim. The court held that, because plaintiffs failed to plead a plausible breach of the duty of prudence by the trustee defendants, the district court properly dismissed their duty to monitor claims against the Board and Lifetouch because those claims cannot survive without a sufficiently pled theory of an underlying breach. View "Vigeant v. Meek" on Justia Law

The Bankruptcy Appellate Panel affirmed the bankruptcy court's orders dismissing debtors' individual chapter 13 cases with a bar to re-filing for 180 days. The panel held that the bankruptcy court did not abuse its discretion where debtors acted in bad faith. In this case, debtors have filed eight chapter 13 bankruptcy petitions between 2010 and 2018, and the bankruptcy court found that debtors' filings were part of a long-running scheme to manipulate and abuse the Bankruptcy Code and the bankruptcy system to the extreme detriment of their creditors, particularly Wilmington Savings. View "Steiner v. Wilmington Savings Fund Society" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence seized at his residence, as well as statements he made to officers at his residence and at the police station. The court held that the search warrant was supported by probable cause where defendant had prior drug convictions for possession and manufacturing/delivery of controlled substances; a search of the trash at his residence yielded evidence of illegal drug activity; and a rental car was located in the driveway along with defendant's own vehicle.The court also held that the district court did not abuse its discretion in denying a Franks hearing where defendant failed to make either the requisite showing of intentional or reckless falsehood or omission, or that the probable cause analysis would change if the affidavit was modified as suggested. View "United States v. Turner" on Justia Law

The Eighth Circuit denied a petition for review of the BIA's dismissal of petitioner's appeal of the IJ's denial of cancellation of removal relief and denial of petitioner's motion to remand. The court held that the BIA did not engage in impermissible factfinding when it agreed with petitioner that one of the IJ's findings was clearly erroneous. In this case, the BIA evaluated the same record as the IJ; noted the IJ's factual error and its lack of prejudicial impact; and concluded after weighing and evaluating the other evidence that exceptional and extremely unusual hardship was not established.The court also held that the BIA's weighing of hardship factors was a discretionary determination beyond the court's jurisdiction. Finally, the court held that the BIA did not abuse its considerable discretion in concluding that petitioner failed to provide any new and previously unavailable evidence regarding his qualifying relative. View "Campos-Julio v. Barr" on Justia Law

Green Plains, owner and operator of an ethanol production facility, filed suit against PEI for negligence and products liability, alleging defective design and failure to adequately instruct and warn users. The district court granted summary judgment to PEI.The Eighth Circuit held that reasonable minds could differ about whether the regenerative thermal oxidizer (RTO) was defective, and thus Green Plains submitted sufficient evidence of a defective design to survive summary judgment. Furthermore, reasonable minds could disagree as to whether PEI could foresee that a company would view the "suggested" maintenance as mandatory, or would ignore it due to the effort required. Therefore, under Minnesota law, the court held that PEI was not entitled to summary judgment on proximate cause. Finally, the court held that the district court properly granted summary judgment on the failure-to-warn claim. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Green Plains Otter Tail, LLC v. Pro-Environmental, Inc." on Justia Law

Plaintiffs filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), alleging that Blue Cross abused its discretion by partially denying their claim for air-ambulance benefits under an employee health plan. The district court granted summary judgment in part to Blue Cross and in part to plaintiffs.The Eighth Circuit held that the wrongful denial of plan benefits breaches the parties' contract and deprives the participant of the benefit of their bargain. Therefore, this constitutes an injury to the participant—even if the benefits are assigned to a third party. In this case, plaintiffs satisfied the injury-in-fact component of constitutional standing. The court also held that plaintiffs had statutory standing, because they have alleged a colorable claim that Blue Cross unreasonably prevented the "Allowed Charge" for "Ambulance Services" and denied their claim for benefits based on that interpretation.On the merits, the court held that Blue Cross did not abuse its discretion by partially denying plaintiffs' claim. The court wrote that the plan gave Blue Cross broad discretion to determine the "Allowed Charge" for air-ambulance services, and Blue Cross has adopted a consistent interpretation, tied to an external benchmark, which is compatible with both the plan's language and its purpose. Finally, the court held that Blue Cross did not abuse its discretion in interpreting the "medical supply" fee language. View "Mitchell v. Blue Cross Blue Shield of North Dakota" on Justia Law

The Bankruptcy Appellate Panel reversed the bankruptcy court's order denying BOM's motion under 11 U.S.C. 506(b) for allowance of postpetition default interest.The panel held that the bankruptcy court erred in applying a liquidated damages analysis and ruling the default interest rate was an unenforceable penalty under Missouri law; the panel made no decision as to whether and when the default interest rates under the notes at issue were triggered under the facts of this case, because such decisions are mixed questions of law and fact that are best left for the bankruptcy court to decide in the first instance; the panel endorsed the view that post-Ron Pair, the pre-confirmation interest rate to be applied under section 506(b) to an oversecured creditor whose claim is evidenced by a promissory note or similar loan agreement is the contract (both non-default and default) rate set forth in the note or loan agreement, to the extent enforceable under applicable law; the panel held that, absent state law to the contrary, a liquidated damages vs. penalty analysis is not applicable and should not be applied to a default interest rate set forth in a promissory note or similar loan agreement; and the panel followed the rule that equitable considerations should be used sparingly and only in exceptional circumstances. Accordingly, the panel remanded for further proceedings. View "The Bank of Missouri v. Family Pharmacy, Inc." on Justia Law

The Bankruptcy Appellate Panel affirmed the bankruptcy court's decision applying the contemporaneous exchange for new value preference defense under Bankruptcy Code 547(c)(1) to except payments by debtor to Wells Fargo from avoidance as preferences.The panel held that new value was provided by the release of Wells Fargo's junior liens where a senior lienholder voluntarily released its liens for less than full payment of its debt; Wells Fargo provided new value to debtor when the IRS, a secured creditor senior to Wells Fargo, was paid from the proceeds of a sale of debtor's assets and voluntarily released its liens; a $100,000 payment made by debtor to Wells Fargo one day before a sale closing was intended to be a contemporaneous exchange; and Wells Fargo's release of claims against Phillips 66 and KCRC resulted in new value to debtor intended by the parties to be a contemporaneous exchange. View "Lauter v. Wells Fargo Bank" on Justia Law

The Eighth Circuit affirmed the district court's order granting SnugglyCat's motion to voluntarily dismiss this Lanham Act action without prejudice pursuant to Federal Rule of Civil Procedure 41(a)(2). The court rejected appellants' contention that the district court failed to consider their argument regarding legal prejudice; the court saw no need to adopt a per se rule that would bar dismissal without prejudice in all cases in which a plaintiff has sued under a fee-shifting statute and found that the district court did not commit an error of law; and the district court did not commit a clear error of judgment where it considered all the relevant factors, including SnugglyCat's purported reason for seeking dismissal of the action without prejudice—its inability as a small company to sustain the cost of continuing suit—and expressly found the motion to have been made in good faith. View "SnugglyCat, Inc. v. Opfer Communications, Inc." on Justia Law